No carbon number, no deal: Europe’s carbon rules are redefining trade

By Jonas Bengtsson, Co-founder & Director of Impact and Expert Advisor to Rebuilt

In Europe, a product without a carbon number is starting to look like a phone without internet access, technically functional, but commercially obsolete. It’s no longer just about sustainability; it’s about market access, procurement decisions, and regulatory compliance. Product Carbon Footprints (PCFs) are becoming a default requirement for trade, and Australia risks being locked out of future markets if it doesn’t act now.

Regulators in the EU are embedding PCFs into law. The Carbon Border Adjustment Mechanism (CBAM) already requires importers of carbon-intensive goods like cement and steel to report embedded emissions. Next year, they’ll start paying for those emissions. Meanwhile, the upcoming Digital Product Passport (DPP) regulation will mandate machine-readable PCFs for priority product groups by 2027, and for all products by 2030.

Major companies are not waiting. BASF can already calculate PCFs for 45,000 products using an in-house tool. BMW and Ford require suppliers to include PCF data in contracts. Unilever expects its suppliers to provide product-specific carbon data, and construction giants in Europe and the US are increasingly insisting on Environmental Product Declarations (EPDs), formal disclosures that often include PCFs, to win bids.

These moves are being driven not only by regulation, but by supply chain pressure, where emissions from purchased goods and services dominate. In sectors like retail and construction, Scope 3 often accounts for over 90% of emissions. That’s why procurement teams are asking not “what’s your strategy?” but “what’s the carbon footprint of your product this year?”

From my vantage point, working with global businesses and policy settings, I see what’s happening in Europe as a clear signal of what’s to come.

This is why I think Rebuilt is spot on and well positioned to prepare Australia for business requirements that are only going to continue to grow.

What Rebuilt is doing isn’t just responding to today’s demands, it’s anticipating the structural changes that are reshaping how products will be assessed and traded. The ability to generate machine-readable PCFs at scale is becoming foundational infrastructure for manufacturers’ compliance. And Rebuilt’s approach—grounded in automation, usability and industry relevance, positions it well to support Australian suppliers as expectations accelerate.

What’s especially important is that Rebuilt is acting early. Rather than waiting for policy changes to land domestically, it’s looking ahead, drawing from European and North American precedents to help local industry build capability now, rather than scramble later. That kind of foresight can give companies the time and space they need to integrate carbon transparency into their core operations, not bolt it on as a last-minute compliance fix.

And crucially, Rebuilt is helping to bring clarity. PCFs and EPDs are often used interchangeably, but they serve different purposes. PCFs (ISO 14067) provide carbon-specific data, typically cradle-to-gate. Rebuilt have added independent verification processes (ISO14064-3) to meet requirements from programs like NABERS, Green Star and ISC. EPDs (ISO14025, EN15804 for construction products) are independently verified by definition and include a carbon assessment alongside a broader range of environmental indicators. I see PCFs as an accessible foundation, a building block for more complete environmental transparency and better decision-making.

The signal is clear: product-level carbon data is becoming core to how goods are valued, traded, and regulated. As other markets bake these expectations into law and procurement, Australia must decide whether to lead, or be left catching up. Platforms like Rebuilt won’t solve the challenge alone, but they are a crucial part of the solution: enabling transparency, simplifying data exchange, building capability, and giving Australian industry a head start on what’s already unfolding globally.